Privacy

The information appearing below is the Privacy Policy of Marbella Golf Country Club (Pacific Golf S.L.), confirming their role as Data Controller. This statement collects all the information of interest to you as per the guidelines of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regulating the protection of individuals regarding the processing of their personal data and the free movement of such data.

To begin with, we must inform you of the Data Controller’s contact details, so that you may send any request or notification you wish to make, including the exercise of your rights, which we will explain later.

Marbella Golf Country Club (Pacific Golf S.L.)

Tax ID code: B29492592

Address: Ctra de Cádiz, N-340 Km.188, 29604, Marbella

Email: sandra@marbellagolf.com

Which personal data do we process and why?

In general, the Data Controller processes the data provided by the members/customers directly, with the understanding that the data are always real and truthful. No superfluous or unnecessary data is collected. Data is always adjusted to the minimum legal and organisational needs necessary to provide the requested service of any kind. The purpose of the processing of this information will depend on the service requested and may be:

• Administration and commercial management of the services provided

• Accounting and tax management

• Appropriately address the requests for information received through any means

• Manage golf course bookings made by any means

• Administer news, events and posts on our websites and social media profiles

• Sending newsletters and/or emails with information on competitions, events and news relating to the Golf Club, which may be of your interest as member/customer

• Manage collections

• Sale and rental of material from our facilities

• Manage catering and restaurant services

The personal data you provide, which are processed by the Data Controller for the mentioned purposes, are:

• Full name.

• Postal address and email address.

• Telephone.

• Date of birth/age.

• Credit card details.

• Data regarding registration with the Spanish Golf Federation or their regional departments, which may include handicap and sporting achievements.

• Historical data regarding the use of the Club’s services, such as bookings, attendance to competitions and events, including your image in photographic material and videos obtained during these events for promotional purposes on the Club’s website and social media profiles.

What is Marbella Golf & Country Club’s legitimation for the use of the personal data?

Legitimation is the legal basis on which the Data Controller considers himself/herself authorised to use and process the data specified above and which are, depending on the processing in question:

1. Legitimation due to a legal obligation. Some processing is carried out because there are different kinds of regulations and laws that oblige the Data Controller to process its clients’ information, including communication and historical archiving of the same.

2. Legitimation for the execution of a contract. Membership or a simple booking of a game or rental of sports equipment means that you have contracted a service with the Data Controller, who will need specific information to fulfil its part of this agreement satisfactorily and safely for its interests.

3. Consent of the data subject. In some cases, such as club membership or web-based requests for services, we may also ask you to agree to this privacy policy so that we can use your information with your express consent.

4. Legitimate interest. For the processing in respect of advertising and commercial prospecting of services and products offered by the Data Controller, including direct marketing and in accordance with Section 47 of EU Regulation No 2016/679 and the Opinion of the Working Party in Section 29 revised in April 2018, the concept of legitimate interest includes both conventional prospecting and other forms of marketing or advertising, where the use of certain specific data is necessary and unavoidable and in no case poses a high objective risk to the rights of the data subjects.

For how long is your data processed?

The Data Controller stores or processes your data indefinitely, unless you have duly requested otherwise. In any case, the minimum retention periods established in the tax and accounting regulations, as well as in the Commercial Code and complementary regulations, must be complied with.

With whom is your information shared?

The Data Controller will not share any data with third parties for purposes other than those described above without your express permission and will only do this under legal obligation.

Your individual rights

You have the right to request the following actions from us:

• Access to your personal data

• Correction of your personal data

• Limitation of the personal data processing

• Purpose of the personal data processing

• Portability of your data to third parties or entities.

You can request the execution of these rights through a request to the Data Controller, sent to the contact means described above. Note that you must be properly identified and clearly state the reason for your request. You must also indicate an address or contact details to be answered formally.

The Data Controller reserves the right to modify this privacy policy without prior notice to adapt it to new legislation or new processing or business practices.